Full Breakdown
Melania Trump Wins Dismissal of Michael Wolff’s Preemptive Anti-SLAPP Suit
5/26/2026, 10:08:51 PM
Federal Court Rejects Wolff’s Preemptive Lawsuit
On May 22, 2026, U.S. District Judge Mary Kay Vyskocil dismissed author Michael Wolff’s anti-SLAPP action against former First Lady Melania Trump (Wolff v. Trump, No. 1:25-cv-10752). The judge called the filing “inappropriate tactical gamesmanship” and declined to rule on the underlying defamation claim.
Background
In October 2025, Trump lawyer Alejandro Brito warned Wolff that the first lady would sue for $1 billion if he did not retract statements linking her to convicted sex-trafficker Jeffrey Epstein. Wolff responded by filing an anti-SLAPP suit in New York state court, seeking a declaration that his remarks were non-defamatory and that any future suit would violate New York’s anti-SLAPP protections. The case was transferred to federal court in December 2025.
Legal Reasoning
Judge Vyskocil said Wolff engaged in “textbook bad-faith forum shopping” by seeking a pre-emptive ruling before any defamation suit existed. She noted that Melania Trump’s primary residence is in Florida, the likely venue for any suit, and that while federal jurisdiction existed, the court would not exercise it. The decision stressed that parties must litigate “according to the same procedures as everyone else.”
Official Statements
Spokesperson Nick Clemens said the first lady is “proud to continue standing up to, and fighting against, those who spread malicious and defamatory falsehoods.” Melania Trump told reporters that the false claims linking her to Jeffrey Epstein must end and described the accusers as lacking ethical standards, humility and respect.
Criticism
Wolff, on the Inside Trump’s Head podcast, vowed to keep fighting, described the dismissal as a scathing example of inappropriate tactical gamesmanship, and questioned whether a judge appointed by Donald Trump could be impartial.
Conflicting Reports
All sources agree the judge declined to address the merits, but they differ on whether she ruled on Trump’s Florida residency; the $1 billion suit remains unfiled.
Verbatim Quotes
- “But the outcome is simple. The Court will not be conscripted to oversee an abusively presented spat and so declines to reach the merits here.” — Judge Mary Kay Vyskocil
- “The lies linking me with the disgraceful Jeffrey Epstein need to end today.” — Melania Trump
- “But I think, fundamentally, it’s the question now of, can we get before a judge who is not a Trump judge?” — Michael Wolff (Inside Trump’s Head podcast)
- “plaintiff asks for a declaration that, if the first lady sues him, he deserves to win. That is not how the federal courts work.” — Judge Mary Kay Vyskocil
- “an inappropriate level of tactical gamesmanship.” — Michael Wolff, author
What’s Next
Wolff may appeal in state and federal courts and seek a venue without a Trump appointee, while Melania Trump’s team is expected to pursue the threatened defamation action in Florida, where jurisdiction appears strongest.
